Privacy Policy

1. Controller & Contact

The data controller responsible for processing your personal data is:

ClearFin GmbH
Blegistrasse 7, 6340 Baar, Switzerland
Email: privacy@clearfin.ch
Website: www.clearfin.ch

2. Applicable Law

This Privacy Policy is governed by the Swiss Federal Act on Data Protection (revDSG / nFADP), which came into force on 1 September 2023, and, where applicable, the EU General Data Protection Regulation (GDPR) for individuals in the European Economic Area.

3. Data We Collect

3.1 When you visit our website

• •IP address (anonymised after 24 hours)
• •Browser type and version
• •Pages visited and time of visit
• •Referring URL

This data is collected automatically via server logs and is used solely to ensure technical functionality and security.

3.2 When you contact us

• •Name and email address
• •Company name and role (if provided)
• •Content of your message

3.3 When you engage our services

• •Contact and billing information
• •Communication history
• •Data required for contractual performance and invoicing

4. Legal Basis for Processing

We process your personal data on the following legal grounds:

• •Contractual necessity – to fulfil a contract or take pre-contractual steps at your request
• •Legitimate interest – for website security, analytics, and business communications
• •Legal obligation – where Swiss law requires us to retain records (e.g. VAT, commercial law)
• •Consent – where explicitly provided (e.g. newsletter subscription)

5. How We Use Your Data

• •Providing and improving our financial consulting services
• •Responding to inquiries and managing client relationships
• •Fulfilling statutory accounting and record-keeping obligations
• •Ensuring the security and integrity of our website
• •Sending service-related communications

6. Data Sharing

We do not sell, rent, or trade your personal data. We may share data with trusted third parties only in the following circumstances:

• •Service providers – hosting, IT support, and communication tools operating under data processing agreements
• •Professional advisors – lawyers, auditors, and accountants bound by confidentiality obligations
• •Authorities – where required by Swiss law or a valid court order

Any third-party processors are contractually required to handle your data in accordance with applicable data protection law.

7. International Data Transfers

Where data is transferred outside Switzerland or the EEA, we ensure an adequate level of protection through Standard Contractual Clauses (SCCs) or by transferring only to countries recognised by the Swiss Federal Council as offering adequate protection.

8. Retention Periods

• •Website logs: 30 days, then anonymised or deleted
• •Contact inquiries: Up to 2 years unless a client relationship is established
• •Client and contract data: 10 years from end of contract (Swiss Code of Obligations, Art. 958f)
• •Invoice records: 10 years (Swiss VAT law)

9. Your Rights

Under the revDSG and, where applicable, the GDPR, you have the right to:

• •Access – obtain a copy of the personal data we hold about you
• •Rectification – request correction of inaccurate data
• •Erasure – request deletion of your data, subject to legal retention obligations
• •Restriction – request that we limit processing in certain circumstances
• •Portability – receive your data in a machine-readable format
• •Objection – object to processing based on legitimate interest
• •Withdraw consent – at any time, without affecting the lawfulness of prior processing

To exercise any of these rights, please contact us at privacy@clearfin.ch. We will respond within 30 days.

If you believe your rights have not been respected, you have the right to lodge a complaint with the Swiss Federal Data Protection and Information Commissioner (FDPIC) at www.edoeb.admin.ch.

10. Cookies

Our website uses only technically necessary cookies required for basic functionality. We do not use tracking, advertising, or analytics cookies. No cookie consent banner is displayed, as no non-essential cookies are placed.

11. Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These include encrypted connections (TLS/HTTPS), restricted access controls, and regular security reviews.

12. Changes to This Policy

We may update this Privacy Policy from time to time. The current version is always available at clearfin.ch/privacy. Material changes will be communicated via email where we hold your contact details.